FSMA Produce Safety Rule or GAPs?

The FSMA Produce Safety Rule compliance dates began January 26, 2018 for most requirements, except the agricultural water related requirements. The largest farm businesses have to meet this earliest compliance date, with small and very small farm businesses having an additional one year, and two years (respectively) for most requirements.

Now that the first wave of produce farm businesses are becoming regulated for the very first time, I thought it might be good to look at the differences between the FSMA Produce Safety Rule and GAPs (good agricultural practices).

Some questions might be…

Does the Produce Safety Rule replace GAPs?

As a farm, do I have to do both?

Do they work together?

Naturally, the answer to each of these questions is not so straightforward. First, lets look at a summary of both the FSMA Produce Safety Rule and GAPs:

FSMA Produce Safety Rule

This is a newly mandated program that governs the on-farm practices of growing certain fruits and vegetables. The list of covered crops is long, but basically any produce crop that is likely to be eaten raw is covered.

The Produce Safety Rule is a science- and risk-based approach that aims to minimize or prevent contamination of produce instead of react to an outbreak after the fact. It covers 5 identified contamination routes:

• worker health and hygiene
• agricultural water
• soil amendments of animal origin
• wildlife and domestic animals
• sanitation of tools, equipment and buildings

Baseline criteria and standards are prescribed, however, each farm has the flexibility to determine how they will comply, based on their specific farm operations. Food safety plans are NOT required, but the Produce Safety Rule requires records to be kept.

Some farm operations may be exempt from the Produce Safety Rule, but all farms are encouraged to comply with the standards to improve the quality of the US food supply.

GAPs (Good Agricultural Practices)

Prior to FSMA, the FDA and USDA developed the Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, (released 1998). The common name is GAPs (Good Agricultural Practices ) and GAPs are voluntary guidelines for those grow, harvest, pack and transport produce. Guidance is given for the following points of contamination:

• agricultural water
• worker health and hygiene
• soil amendments
• sanitary facilities -restrooms and handwashing for workers, volunteers and customers
• field sanitation – harvest bins, totes, knives and equipment
• pack facility sanitation – sorting tables, bins, equipment, and pest control
• transport – growers, packers, distributors, wholesalers, etc.
• traceback

GAPs Audits

Although voluntary, GAPs compliance is also market and consumer driven. Buyers, farmers market organizations, school districts and consumers may require a farmer have a GAP audit as a condition of purchase, or presence at a farmers market.

Audits are conducted by 3rd party organizations (both government and private sector organizations), usually at a cost to the grower. In preparation for the audit, it is generally necessary for a farm to have a written food safety plan and at least one growing season of documentation for an audit to be performed.

As a grower in need of a GAPs audit, make sure to ask questions of your buyer(s) before hand and research the type of audit you need.

The USDA Produce GAPs Harmonized Standards  is a combination of the official two separate Produce GAPs Harmonized Food Safety Standards posted on the United Fresh website.

The ‘Harmonized GAPs’ standards (generally meaning GAPs) are designed to meet the majority of buyer requirements (with riders added as necessary). Just know if you need a ‘Field Operations and Harvest’ focused audit or a ‘Post Harvest Operations’ focused audit, or if you want both.

Produce Safety Rule or GAPs?

At the beginning of this article, we posed potential questions about compliance with the Produce Safety Rule or GAPs. Let’s review potential answers.

Does the Produce Safety Rule replace GAPs?

No. The Produce Safety Rule should be considered a baseline level of produce safety. GAPs are market driven, and buyers or consumers may ask for a written food safety plan or audit as a condition of sale.

As a farm, do I have to do both?

It depends. A farm’s business size (as defined in the Produce Safety Rule) and the crops grown will determine if they are regulated by the produce safety rule. As an additional standard, a farm’s buyer(s) may require them to have a written food safety plan only, or perhaps a food safety plan and GAPs audit.

Do they work together?

Probably, but at this writing, it’s not clear the exact extent. The Produce Safety Rule requires certain recordkeeping, but not an actual food safety plan. That recordkeeping will be a good start on a food safety plan but additional documentation is probably required.

Pam

Pam offers experienced, professional, freelance B2B copywriter, consultant and trainer services primarily on produce safety, local foods, and public health topics.  She writes all forms of B2B content on other topics, too, and helps clients develop a content strategy to meet their goals. She also writes on

happyrealwomen.com

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4 Reasons to Have a Food Safety Plan

You’re busy doing what you do best – and love – growing, beautiful, mouthwatering fruits and veggies.  Who has time for paperwork, right?

I hear you!

I don’t care how good Your food safety plan is,  if it’s  IN.  YOUR.  HEAD.  it’s only good for the person who has access to it, YOU!

I hate to break it to you, but if a food safety plan isn’t documented, it doesn’t count.  Here are 4 reasons to have a food safety plan (and there are probably more):

1.   No worker can follow it – as a farm manager or operator, you can’t be everywhere all the time.

• What time of day (outdoor temperature) do you aim to finish harvesting for optimal crop quality,
• Do you have to wash and sanitize tools before harvesting,
• How to mix sanitizers.

2.   No buyer can review it – check to see how you are handling  key aspects of your farming operation.

• Crop cooling at harvest and during storage and transport to the point of sale,
• What you do if a worker comes to work sick,
• Rules on allowing pets in the fields,
• Application of soil amendments and time to harvest,
• Water quality documentation,
• Or other food safety related questions.

3.   No audit can happen – if you are selling directly to a buyer, they may want to do an informal food safety plan review and audit themselves.  Other wholesale or retail buyers may require a 3rd party audit as a part of the transaction.

• You can’t write a plan at the time of harvest, when you are negotiating a sale to a wholesale or retail buyer
• Not documenting an existing written plan’s practices (with receipts, SOPs, log sheets, water test results, etc) on what you did during the growing season

4.   No proof can exonerate you during an outbreak – if your farm’s crop(s) are identified as potentially being part of a suspected outbreak, you want to quickly be able to clear your farm’s name from suspicion.

Fine Tune Your Food Safety Plan

The good news is that you probably already have good agricultural practices in place on your farm.  Maybe it just isn’t written down in a food safety plan.  You probably even have some informal documentation happening in various forms – pocket-sized notebooks, email receipts and the like.

With the new Food Safety Modernization Act (FSMA) produce rules finally in effect, the earlier in your growing season would be a good time to see how your existing practices measure up.  That way you can start the season off on the right foot.

I would hate to see you miss out on a sale because you don’t have a food safety plan.

If you need help reviewing your existing plan or documenting your food safety practices better, let me help.

So YOU can get on with growing that beautiful produce!

Pam

Pam offers experienced, professional, freelance B2B copywriter, consultant and trainer services primarily on produce safety, local foods, and public health topics.  She writes all forms of B2B content on other topics, too, and helps clients develop a content strategy to meet their goals. She also writes on

happyrealwomen.com

The post 4 Reasons to Have a Food Safety Plan appeared first on Happy People Enterprises.

Choosing the right consultant can be challenging.  You want someone that has experience, industry knowledge, and of course, innovative ideas.

No one likes to send their staff to ‘canned’ training programs, hoping they’ll walk away knowing how to apply what they’ve learned.  And it doesn’t matter how good the presentation – if you don’t know how to use it – it doesn’t help your organization much, and you go away feeling frustrated.

Same thing goes with hiring a consultant. You need someone who has some experience in your field.

Experience in Regulatory Compliance and Enforcement

We have experience in regulatory compliance and enforcement environment; understand what it’s like to tell people what they can or can’t do with their property, and know that every decision costs them money.  We’re also familiar with working with consultants, engineers, contractors and property owners, all experts in their field, and with differing levels of technical understanding.  In this environment it’s important to connect with people the first time.

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Why Us

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• Copywriting

Copywriting is a normal part of most businesses, whether you need whitepapers, case studies, annual reports, blog posts, SEO website copy or something else. We are experienced in a wide variety of Business to Business copywriting products.

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Happy People Enterprises  is experienced in FSMA  and GAPs produce safety, local foods and public health consulting for both private sector and government agencies.  Check out our consulting capabilities for more information.

• Training 

Happy People Enterprises provides off-the-shelf and customized training and development programs, to businesses, organizations, and government agencies.  We go to you, works with your staff and helps them work with real-world problems.  We develop specific training and development programs customized to your needs.

Programs are presented in a positive, affirming environment that acknowledges the worth of every individual and every personality perspective.  Our training programs offer a fun-filled, interactive experience – we help you immediately apply what is learned. Programs are customized into half-day, one day or two day long trainings, depending on your desired outcomes and objectives.
For more detailed information on why you should book your training with us, see 5 Reasons to Book Your Training with Us.

Contact Pam  for a free consultation, or to find out more about how Happy People Enterprises can help your business, organization or government agency.

Pam

Pam offers experienced, professional, freelance B2B copywriter, consultant and trainer services primarily on produce safety, local foods, and public health topics.  She writes all forms of B2B content on other topics, too, and helps clients develop a content strategy to meet their goals. She also writes on

happyrealwomen.com

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